MORELLI v. COMMISSIONER

Docket No. 9082-79.

42 T.C.M. 89 (1981)

T.C. Memo. 1981-293

John D. Morelli, Jr. v. Commissioner.

United States Tax Court.

Filed June 16, 1981.


Attorney(s) appearing for the Case

John D. Morelli, Jr., pro se, Garnerville, N.Y. Howard C. Rosenblatt, for the respondent.


Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's 1977 Federal income tax of $1,414.1 Petitioner has alleged no errors committed by respondent in respect of the specific elements of his deficiency determination, see Rule 34(b)(4), Tax Court Rules of Practice and Procedure, and the only issue for decision is whether the respective burdens of proof of the parties have been met.

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